Case Digest (G.R. No. L-23832)
Facts:
The case involves Proceso Apolega as the petitioner and Perseveranda Hizon, Luciano Alcantara, Mariano Primicias, Prudencio D. Dequina, Amado M. Enriquez, Hon. Cesario Perez, and the Provincial Sheriff of Biñan, Laguna as respondents. The events leading to the case began on May 26, 1961, when Melanio Hizon filed a notice of claim for compensation with the Regional Office No. 5 of the Department of Labor in San Pablo City, due to an injury he sustained on January 5, 1961, while employed by Proceso Apolega. On June 16, 1961, the petitioner received a letter from the Chief of the Administrative Section of the Regional Office, along with forms to fill out regarding the claim. However, the petitioner did not complete these forms, claiming instead that he verbally informed the office that Hizon was not his employee. On July 21, 1961, Regional Administrator Luciano Alcantara issued an award requiring the petitioner to pay Hizon P158.90 for medical expenses, P3,744.00 for compensatio...
Case Digest (G.R. No. L-23832)
Facts:
- Injury Claim: On May 26, 1961, Melanio Hizon filed a notice of claim for compensation with Regional Office No. 5, Department of Labor, San Pablo City, for an injury sustained on January 5, 1961, while employed by Proceso Apolega (petitioner).
- Employer's Failure to Respond: Petitioner received forms to fill out regarding the claim but failed to do so, alleging he verbally informed the office that Hizon was not his employee.
- Initial Award: On July 21, 1961, Regional Administrator Luciano Alcantara issued an award requiring petitioner to pay P158.90 for medical expenses, P3,744.00 as compensation benefits, and P38.00 as fee.
- Death of Melanio Hizon: On November 30, 1962, Melanio Hizon died from complications of the injury. His widow, Perseveranda Hizon, filed a death compensation claim on January 22, 1963.
- Death Compensation Award: On February 22, 1963, an award was issued in favor of Hizon’s widow and children for P328.90 (medical expenses), P200.00 (burial expenses), P3,744.00 (compensation benefits), and P38.00 (fee). This award was renewed on July 8, 1963.
- Petitioner’s Inaction: Petitioner failed to file a motion to vacate the award despite being granted an extension. The award was declared final and executory on September 9, 1963.
- Writ of Execution: On July 24, 1964, the Workmen’s Compensation Commission affirmed the award, and a writ of execution was issued against petitioner’s properties.
- Petition to the Supreme Court: On November 17, 1964, petitioner filed a petition for certiorari and prohibition, challenging the award and the constitutionality of Section 17 of Republic Act 4119.
Issue:
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Ruling:
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Ratio:
- Timeliness of the Claim: The failure to file the claim within the two-month period prescribed by Section 24 of the Workmen’s Compensation Act is non-jurisdictional and does not bar the proceeding, especially since the employer did not suffer prejudice from the delay. Partial payment of benefits by the petitioner also rendered the time limit inapplicable.
- Notice and Hearing: Petitioner’s failure to controvert the claims waived his right to present evidence. The hearing officer was justified in treating the claim as uncontested and issuing the award without a formal hearing.
- Constitutionality of Section 17, Republic Act 4119: The grant of authority to the Workmen’s Compensation Commission to issue writs of execution is constitutional. Execution is a procedural step in enforcing awards, and Congress has the authority to legislate on matters of procedure under Section 13, Article VIII of the Constitution.